The Federal Communications Commission had introduced the “one-to-one consent” rule, which mandated that telemarketers obtain explicit consent from consumers for each individual seller before initiating contact. This rule aimed to enhance consumer protection by ensuring that consent was specific to each entity, thereby preventing broad or ambiguous permissions.
However, on January 24, 2025, the FCC announced a postponement of the rule’s implementation, delaying its effective date until at least January 26, 2026, or pending further judicial review. This decision was influenced by a ruling from the U.S. Court of Appeals for the Eleventh Circuit, which vacated the rule, stating that the FCC had exceeded its statutory authority under the Telephone Consumer Protection Act. The court found that the rule’s requirements conflicted with the ordinary statutory meaning of “prior express consent.”
This postponement offers a significant reprieve for sales and telemarketing teams who were concerned about the potential impact on their operations. While compliance with existing Do Not Call lists and litigator lists remains essential, the delay allows these teams to continue their outreach efforts under the current regulatory framework. This period provides an opportunity to maximize customer acquisition and adapt to the evolving regulatory environment.